Understand the procurement standards in the Uniform Guidance (2 CFR 200.317–.327). Learn the five methods of procurement, compliance tips, and best practices for federal grant management.
When managing federal grant funds, how you purchase goods and services is just as important as what you buy. The Uniform Guidance (2 CFR 200.317–.327) lays out procurement standards to ensure purchases are fair, transparent, and compliant with federal requirements.
For grant recipients, following these rules protects your organization from questioned costs, audit findings, and reputational risk. It also ensures that taxpayer dollars are spent responsibly and competitively.
These standards are a core focus of many federal grant management trainings because procurement errors are one of the most common problem areas identified in audits.
The Uniform Guidance outlines five primary methods for purchasing goods and services with federal funds:
1. Micro-Purchases- Purchases under the current micro-purchase threshold (set by the federal government)
- Can be awarded without soliciting competitive quotes, if the price is reasonable
- Still requires documentation of compliance with internal controls
2. Small Purchases- Purchases above the micro-purchase level but below the simplified acquisition threshold
- Require price or rate quotes from an adequate number of qualified sources
3. Sealed Bids (Formal Advertising)- Used for purchases above the simplified acquisition threshold
- Typically applied to construction projects or contracts awarded based on the lowest price from a responsible bidder
4. Competitive Proposals- Used when conditions are not appropriate for sealed bids
- Evaluations are based on factors such as technical qualifications and price
- Requests for proposals (RFPs) must be publicized, and all proposals must be fairly considered
5. Noncompetitive Proposals (Sole Source)- Used only when competition is not feasible (e.g., a single provider, public emergency, or prior federal authorization)
- Must be justified and documented thoroughly
- Document everything. From quotes to justifications, procurement records must show how the decision was made.
- Maintain written policies. Your organization should have clear procurement procedures aligned with the Uniform Guidance.
- Avoid conflicts of interest. Both actual and perceived conflicts must be addressed.
- Monitor vendors. Just like subrecipients, contractors and vendors must be reviewed for performance and compliance.
These practices are emphasized across grant management courses and webinars because auditors often look closely at procurement files.
- Treating micro-purchases casually without proper documentation
- Failing to get adequate quotes for small purchases
- Relying on sole-source justifications without meeting the strict requirements
- Forgetting to update internal procurement policies to match the latest thresholds and regulations
Procurement standards may feel complex, but they exist to create a level playing field and ensure that grant funds are used wisely. By understanding the five procurement methods, maintaining strong documentation, and aligning your policies with the Uniform Guidance, your organization can stay compliant and avoid unnecessary risks.
Looking for more practical guidance on procurement and other compliance areas? Our
grant management courses and webinars cover the Uniform Guidance in detail, with examples that help teams put the standards into practice.
